Trent M. Doyle

Representative Matters: Advised lithium battery manufacturers and shippers on transportation compliance obligations and secured special permits from DOT to facilitate transport; Provided strategic representation to chemical manufacturers/processors throughout EPA risk evaluation process under amended TSCA; Negotiated first enforceable consent agreement (ECA) under TSCA for environmental monitoring and represented a consortium of companies in providing EPA with draft risk evaluation and request for a manufacturer-requested risk evaluation under TSCA; Represented chemical importer in EPA investigation of CDR reporting practices and negotiated favorable resolution of alleged violations; Prepared comments on EPA TSCA implementation rulemakings on behalf of chemical manufacturers and processors; Successfully petitioned the UN Committee of Experts on Transportation of Dangerous Goods to remove Division 6.1 classification from listing for substance in UN Model Regulations; obtained U.S. DOT support for petition and ultimate removal from DOT regulations and counterparts around the world; Worked with client to obtain reversal of PHMSA decision to deny special DOT permit for landmark cylinder testing and life extension technology; Negotiated favorable settlement of FAA enforcement action involving small package consumer product shipments; Represented pipeline operator in PHMSA investigations and enforcement actions resulting from spill incidents; provided counsel on compliance inspection practices and procedures; Reviewed and advised motor carriers on Hours of Service, Drug and Alcohol Testing, and FMCSA regulatory compliance programs and benchmarking against best practices; Defended facility operator in EPA CAA New Source Review enforcement action and obtained favorable resolution that facilitated continued operation; Provided long-term support to food manufacturer in developing and implementing air permitting strategy at multiple facilities that provides for operational flexibility while achieving corporate compliance and sustainability goals; Conducted audit of Emergency Planning and Community Right-to-Know ACT (EPCRA) reporting practices and procedures for multi-facility operator, self-disclose and correct reporting omissions/issues and obtained full penalty mitigation under EPA's Audit Policy; Provided training to corporate team on hazardous materials compliance obligations impacting product design/labeling/packaging; reviewed portfolio of personal care products and advised on shipping options and opportunities for regulatory relief; Obtained DOT PHMSA approval for new explosive and self-reactive materials for transportation; Advised chemical product manufacturer on transportation packaging, labeling, and approval obligations and opportunities for roll-out of new product to multiple destination countries